10/23/2006 Employers are responsible for Medicare Part D reporting

Under a new Medicare Part D reporting requirement, employers must file an annual Creditable Coverage Disclosure report with the Centers for Medicare & Medicaid Services (CMS). This report will disclose whether the prescription drug coverage offered under the employer’s group health plan is considered creditable or non-creditable.

Below is important information you can share with your group clients that will help them understand and comply with this new requirement.

Important things to know about filing the Disclosure report:

• Groups that offer prescription drug coverage to Medicare-eligible employees must file the Disclosure report once a year. The report for plan year 2006 is due by March 31, 2006.
• If the employer’s plan year does not correspond with the calendar year, they will need to file their Disclosure report within 60 days following the start of their new plan year.
• If there is a change to the employer’s prescription drug coverage that alters its status as creditable or non-creditable, the employer will need to file an amended Disclosure report within 30 days following the effective date of the change.
• The employer—not the carrier or third-party administrator—is responsible for filing the Disclosure report.
• The Disclosure report must be filed electronically with CMS. No other method will be accepted.
• Groups that have been approved for the retiree drug subsidy (RDS) do not need to fill out the Disclosure report for their qualified retirees.

The following information must be provided in the Disclosure report:

• Type of coverage: Defined as Group Health Plan or Employer-sponsored Plan.
• Prescription Drug Options: Defined as different types of health programs (i.e., HMO, PPO, POS, etc.). Does not refer to different drug benefit levels.
• Number of Medicare-Eligible Members: As of the beginning of the plan year. If exact numbers are not available, estimates are accepted.
• Retiree Health Plan reporting separate from the Group Health plan: Defined as a plan that covers retired participants.
• Date of Creditable coverage notification: Asuris sent the letters to members between Nov. 17, 2005, and Nov. 30, 2005. If the employer is not certain about the exact date of notification, they can use the “final date” of the mailing (Nov. 30, 2005) in the Disclosure report.

For more information regarding the regulations, visit the CMS Web site. If you have any questions, please talk with your Asuris Sales contact.

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